Temporary telehealth policies during the pandemic, particularly those related to audio-only, highlighted the capacity of community health centers (CHCs) to increase patient access to care in underserved communities. The National Association of Community Health Centers (NACHC) recently released a report on their survey of CHCs to assess their telehealth experiences over the course of the public health emergency and determine what the effects would be upon termination of temporary policies, and how that would impact their providers and patients. The concern from CHCs about possibly losing the ability to utilize telehealth was significant, with over 90% of respondents saying that without the extension of existing flexibilities it will be difficult to reach vulnerable populations, and over 80% stating that it will lead to worse outcomes for patients with behavioral health needs. Overall, the report suggested that losing audio-only coverage would likely exacerbate existing health disparities.

Prior to the pandemic, health centers faced numerous federal restrictions that limited their ability to use telehealth. According to the report, previously only around 40% had used telehealth and audio-only modalities. Once allowed during the pandemic, however, nearly all CHCs utilized telehealth and delivered critical health care services to 30 million patients. Urban health centers and those serving low-income populations were also found to have higher rates of providing services via telehealth and audio-only, and 92% of health centers said audio-only improved patient access to care. To continue to provide this expanded access to care post-pandemic via telehealth the report discussed the need for Congressional action to permanently remove restrictions around use of audio-only and originating/distant site limitations, as well as ensuring reimbursement parity. In addition, as many states struggle to determine their post-pandemic policies related to telehealth, it has become apparent that the U.S. Department of Health and Human Services (HHS) and Centers for Medicare and Medicaid Services (CMS) must also clarify whether states can continue to allow audio-only coverage under Medicaid and still receive federal matching funds.

The value and necessity of audio-only was stressed throughout the survey. Benefits of audio-only telehealth included:
*Reduced no-show rates
*Improved patient/provider relationships
*Better coordination of care amongst providers and families
*Improved chronic care management

The report concludes that without continued telehealth coverage for CHCs, all of the stated benefits will disappear, create a barrier to the provision of quality health care, and negate the ability for health centers to bring equity and access to underserved communities that would otherwise likely go without needed services. The authors urge the federal government to act and preserve access to care via telehealth in health centers across the country.

Currently, there is active legislation federally and in many states that seeks to expand and extend telehealth and audio-only policies, including those for health centers. The fate of these bills remains unknown, but it is clear that the ideal resolution would need both federal direction and state engagement. A small but limited step was taken with CMS’s newly proposed physician fee schedule (PFS) for 2022. CMS is proposing to expand the definition of a “mental health visit” for CHCs by including mental health services provided through “interactive, real-time telecommunications technology”, including audio-only if the patient is not capable or does not consent to the use of live video. Additionally, the rate paid for eligible services would be at parity. This proposal is still rather narrow, but many of the existing restrictions, as mentioned previously, live in federal statute and must first be addressed by Congress.